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Pte. Ltd., a company in Singapore, along with NEL’s owner and director, Lim Yong Nam.<br />

Finally, the indictment charges Corezing International Pte. Ltd., a company in Singapore that<br />

maintained offices in China, as well as Lim Kow Seng, an agent of Corezing, and Hia Soo Gan<br />

Benson, a manager, director and agent of Corezing. On Oct. 24, 2011, authorities in Singapore<br />

arrested Wong, Nam, Seng and Hia pursuant to a U.S. extradition request. Larijani remains a<br />

fugitive in Iran. The indictment alleges that, between June 2007 and February 2008, the<br />

defendants fraudulently purchased and caused 6,000 modules to be illegally exported from the<br />

Minnesota company through Singapore, and later to Iran, in five shipments, knowing that the<br />

export of U.S.-origin goods to Iran was a violation of U.S. law. The defendants allegedly told the<br />

Minnesota firm and the U.S. government that a telecommunications project in Singapore was the<br />

final destination of the goods. The alleged recipient of all 6,000 modules in Iran was Larijani.<br />

The indictment alleges that, in May 2008, December 2008, April 2009, and July 2010, Coalition<br />

forces found no less than 16 of these 6,000 modules in Iraq where they were being used as part of<br />

the remote detonation devices of unexploded IEDs. The indictment further charges Seng, Hia,<br />

and Corezing with a separate fraud conspiracy involving the illegal export of two types of<br />

military antenna from the United States. The indictment alleges that these defendants conspired<br />

to defraud the United States by causing a total of 55 cavity-backed spiral antennas and biconical<br />

antennas to be illegally exported from a Massachusetts company to Singapore and Hong Kong<br />

without the required State Department license. Larijani was also charged with false statements in<br />

connection with his alleged business dealings with Majid Kakavand, an accused Iranian<br />

procurement agent who has been indicted in the United States for illegally exporting goods to<br />

Iran, including to military entities in Iran involved in that nation’s nuclear and ballistic missile<br />

programs. In coordination with the criminal actions, the Commerce Department announced the<br />

addition of 15 persons located in China, Hong Kong, Iran and Singapore to the Commerce<br />

Department's Entity List in connection with this procurement network. In coordination with the<br />

criminal actions by the Justice Department, the Commerce Department announced on Oct. 25,<br />

2011 the addition of 15 persons located in China, Hong Kong, Iran and Singapore to the<br />

Commerce Department's Entity List in connection with this procurement network. Among<br />

others, Action Global, Amaze International and OEM Hub Co., Ltd., all Hong Kong entities,<br />

were added to the Commerce entity list based on information indicating that they served as front<br />

companies and were related to the other entities named in this procurement network, including<br />

Corezing International. Furthermore, Luo Jie, director of Corezing International, Action Global<br />

and Amaze International, was added to the entity list on the basis of information indicating that<br />

she was specifically involved in the procurement and attempted procurement of U.S. power<br />

amplifiers intended for end-users in China, as well as in the diversion of various U.S.-origin<br />

goods through Hong Kong to Iran. Similarly, Zhou Zhenyong, director of Corezing International,<br />

was added to the Commerce list based on information that he was involved in the procurement of<br />

U.S.-origin items, including U.S.-origin munitions items destined for end-users in China and/or<br />

Iran. This investigation was conducted by ICE, FBI and Department of Commerce’s BIS.<br />

• Radiation-Hardened Circuits to China – On Feb. 3, 2012, Chinese citizen and former California<br />

Department of Transportation (Caltrans) engineer Philip Chaohui He made his initial appearance<br />

in federal court in the District of Colorado after his arrest in San Francisco in connection with his<br />

alleged efforts to export defense articles to China without a State Department license, specifically<br />

more than 300 space-qualified and radiation-hardened computer circuits used in satellite<br />

communications with a total value of nearly $550,000. A Dec. 15, 2011 indictment charged He<br />

with conspiracy to violate the Arms Export Control Act (AECA) and to smuggle goods;<br />

attempted violation of AECA; and smuggling. According to the charges, He, the only employee<br />

of an Oakland company called Sierra Electronic Instruments, arranged for the purchase of more<br />

than 300 radiation-hardened circuits from Aeroflex, a Colorado manufacturer, in May 2011. He<br />

arranged for the purchase after a co-conspirator sent him wire transfers totaling nearly $490,000<br />

22

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